Friday, November 15, 2013

Please Comment for Saving Farms: Sample Letter and Links

I know how much you value your fresh food and the farmers that grow it.  Did you know that family and small farmers' livelihoods could be in danger?
The FDA regulations under the Food Modernization and Safety Act could easily put small and family farmers out of business, leaving us only with the large, mono-crop industrialized farms. This will affect the consumer, too.  Read how:
"Under the proposed regulations, many farmers will be forced to comply with high-cost, industrial-scale regulations, and they will be unable to use traditional, sustainable growing practices. Food hubs and local food businesses will be forced to deal with costly and burdensome paperwork. Ultimately, consumers will face increased food prices and reduced availability of locally and sustainably produced foods."
You can read the full article here:
How can you help?
Please submit your comments to the FDA before midnight tonight.  The complete information is available via the Farm to Consumer link above.  I urge you to read it and understand the issues.  However, I've simplified the sample letter and links where to paste it.
Copy and paste my sample letter onto the two places for comments.  Links below. 
On-Farm Produce Rule
Preventive Control HARPC rule:
Lisa's sample letter:  Put your name after "Sincerely,"
"Nov 15, 2013
 Division of Dockets Management (HFA-305)
 Food and Drug Administration
 5630 Fishers Lane, Room 1061
 Rockville, MD 20852

Re: Preventive Controls Rule: FDA-2011-N-0920 and RIN 0910-AG36
 Produce Standards Rule: FDA-2011-N-0921, and RIN 0910-AG35
I am a consumer of fresh farm food.  I am deeply concerned about the impact that FDA’s proposed rules under FSMA would have on the farms that I buy food from.  .
I make a concerted effort to buy from farms that use sustainable practices because it is better for the environment, for the animals and for human beings.
I urge the FDA to address the following issues in the proposed FSMA rules:
TESTER-HAGAN “QUALIFIED EXEMPTION” in both the Produce Rule and the Preventive Controls Rule:
1. The gross sales test to qualify for the Tester-Hagan provision should be based on sales of food that is subject to FSMA, whether the produce standards or the preventive controls rule. Sales of food that would not be regulated under FSMA should not be included.
 2. The FDA should not rush the process of revoking a producer’s Tester-Hagan exemption. The agency has other mechanisms it can use if there is an immediate threat of foodborne illness.
a) The FDA should be held to specific evidentiary standards before it can revoke a farmer’s or food facility’s Tester-Hagan exemption.
 b) A farm or facility that is exempt under Tester-Hagan should be given at least 90 days to submit evidence and defend its exemption if FDA seeks to revoke it.
 c) If the exemption is revoked, the farm or facility should have at least two years to come into compliance with the FSMA rules.

1. The FDA’s approach to traditional farming methods, such as diversified livestock-crop farms, the use of working animals, and the use of biological soil amendments, is fundamentally flawed. The agency should not restrict these sustainable methods of farming without data showing an actual, verified increased rate of foodborne illness; the simple fact that these methods include diverse microbiological communities is not a sound scientific basis for restricting them.
 2. The waiting period between applying manure and harvesting the crop should be no more than 4 months, and there should be no waiting period between applying compost and harvesting the crop. The excellent track record for safety on organic farms shows that this standard is sufficient.
 3. Compost teas and other biological inoculants, including normal additives such as molasses, should be treated the same as compost.
 4. Water testing should not be required more often than once a month, and farmers should be able to test less frequently after establishing the safety of their water source through consecutive negative tests. In addition, farmers should be given the option to test for pathogens, rather than having to treat or stop using the water that tested positive for generic e. coli.
 5. The provisions on wildlife and domestic livestock need to be clarified to protect farmers who use biologically diverse farming from field inspectors using their discretion to require measures such as fencing or destruction of habitat.

1. “Very small facilities” should be defined as being under $1 million in total annual sales, adjusted for inflation. Imposing HARPC requirements on businesses smaller than that is unnecessary and overly burdensome.
 2. Any requirement for “supplier verification” should not prevent a facility from purchasing foods or ingredients from farms and facilities that are exempt from the regulations under the Tester-Hagan provision or other exemptions.
 3. Low-risk activities conducted by a farm using its own products, such as making jams, grinding grains, or dehydrating vegetables, should not be subject to these regulations.
 4. Low-risk activities, when conducted off-farm or by multiple farms working together, should not be subject to the same requirements as high-risk processing activities. The requirements should address both the scale of the operations and the level of risk of the activity.
Your Full Name Here"
You will feel good that you have done what you could!

No comments:

Post a Comment

Please leave a comment for me. Thanks!